The new disclosure of Information Regulations – are you prepared?
In our September 2013 newsletter, we mentioned that the Department for Work and Pensions ("DWP") had been consulting on the draft Occupational and Personal Pensions (Disclosure of Information) Regulations 2013. The regulations have now been published and are coming into force on 6th April 2014.
This is a substantial revision and consolidation of the disclosure regulations. The new regulations will replace the 1987 personal pension regulations and the 1996 occupational pension regulations currently in force.
An important addition to the disclosure requirements that will affect many trustees, requires defined contribution schemes that operate any form of lifestyling, to provide details as part of the basic scheme information. The specific requirement is to provide:
"A statement explaining lifestyling, its advantages and disadvantages, and either:
- that lifestyling will be adopted, indicating when lifestyling is likely to be adopted, or
- that lifestyling has been adopted."
This information must be provided again between five and fifteen years before the "member's retirement date". Member's retirement date is defined in the regulations, and is the date that the member has specified to the trustees or managers of the scheme (provided that date is acceptable under the scheme rules) or, if the member has not chosen a retirement date, a date specified by the trustees or managers of the scheme.
This means that schemes will need a default retirement age, even though that is not allowed for employment purposes.